Privacy Policy - SLEEPwindow

This Privacy Policy describes how the SLEEPwindow data collection portal (the "Portal") collects, uses, processes, and protects personal data in connection with the scientific study "Comparaison de deux thérapies cognitivo-comportementales pour traiter l'insomnie" (BASEC 2024-01324). The Portal is used exclusively for the SLEEPwindow study conducted by the University of Geneva (UNIGE) in collaboration with Geneva University Hospitals (HUG).

The Portal uses Google OAuth and Google API services solely to authenticate eligible study participants and, upon explicit participant authorization, to import selected Google Health / Fitbit data required for the study.

1. Data Controller and Contact Information

Data Controller: University of Geneva (UNIGE), in collaboration with Geneva University Hospitals (HUG).

Principal Investigator / Sponsor Contact: Prof. Dr. Christoph Nissen, Geneva University Hospitals (HUG), Department of Psychiatric Specialties, Rue de Lausanne 20, 1201 Geneva, Switzerland.

Study Reference Contact: PD Dr. phil. Elisabeth Hertenstein, Campus Biotech, Chemin des Mines 9, 1202 Genève, Switzerland, elisabeth.hertenstein@unige.ch.

This Portal is intended only for persons who have already been informed about the SLEEPwindow study and who have signed the applicable study consent documentation.

2. Information Collected

2.1 Google account information

When a participant signs in through Google, the Portal uses Google OAuth to authenticate identity and verify that the participant is registered in the study system.

For this purpose, the Portal may access basic Google account information such as the participant's email address, account identifier, and basic profile details necessary for login, account matching, and security logging.

The Portal does not request access to Gmail content, Google Drive files, contacts, calendar content, or other unrelated Google services.

2.2 Google Health / Fitbit data

If a participant explicitly authorizes the connection, the Portal uses Google API services relating to Google Health / Fitbit to import selected health and activity information associated with the participant's connected Fitbit account.

The imported data is limited to sleep-related and activity-related metrics required for the research protocol, such as sleep duration, sleep timing, movement or activity patterns, and rest-related metrics relevant to the SLEEPwindow study.

The Portal is designed to read only the data necessary for the study and does not modify data in the participant's Google or Fitbit account.

3. Purpose of Processing

Personal data and Fitbit-derived data are processed solely for the following purposes:

To authenticate participants and restrict access to authorized study participants only.
To collect study-related sleep and activity metrics needed for the SLEEPwindow research protocol.
To manage study participation, data quality controls, and research analysis under the approved study framework.
To generate coded or aggregated scientific results concerning the treatment of insomnia.

The Portal and the collected Google-derived data are not used for advertising, marketing, commercial profiling, or any unrelated commercial purpose.

4. Legal Basis and Voluntary Participation

Participation in the SLEEPwindow study is voluntary, and use of the Portal is linked to the participant's informed consent to participate in the study.

The related processing of personal data is carried out in accordance with the study information and consent documentation, applicable Swiss human research requirements, and applicable Swiss data protection rules.

5. Pseudonymization, Storage, and Retention

Data imported through the Portal is pseudonymized as soon as reasonably possible and linked to a unique participant code. Direct identifiers such as name and email address are stored separately from study metrics.

Study data is transmitted over secure connections and stored on secure servers located in Switzerland, operated through Infomaniak for hosting infrastructure, with access restricted to authorized personnel only.

The identification key linking a participant's identity to the study code is kept separately by the study team at the University of Geneva.

As described in the study consent materials, study documents and coded study data are retained for at least 10 years after the end of the study, after which they are deleted, archived, or further anonymized in accordance with applicable legal and research requirements.

6. Google API Services User Data Policy

The Portal's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

In particular:

Google user data obtained through the Portal is not sold to third parties.
Google user data is not used for advertising, marketing, or the creation of unrelated user profiles.
Google user data is accessed only as needed to provide and operate the research functions described in this Privacy Policy.
Human access to Google-derived data is limited to authorized study personnel, technical administrators acting under confidentiality obligations, or situations required by law, ethics oversight, or security incident handling.

7. Data Sharing

Coded study data may be shared within UNIGE, HUG, and with authorized collaborators, service providers, analysts, auditors, or ethics/regulatory bodies where necessary for study conduct, hosting, security, compliance, or scientific analysis.

Where data is shared for analysis or oversight, it is shared in coded form whenever possible and subject to confidentiality and legal safeguards.

If data must be transferred outside Switzerland, the study team applies the protections described in the participant consent documentation and applicable Swiss standards.

8. Participant Rights and Revocation

Participants may withdraw from the study at any time in accordance with the study consent documents, without having to justify their decision.

Participants may also revoke the Portal's access to their Google account at any time through their Google account permissions settings or by contacting the study team.

Under applicable Swiss data protection law, participants may have rights of access, rectification, and other rights regarding their personal data, subject to the limits that may apply in regulated research contexts.

Withdrawal from the study or revocation of Google account access does not necessarily require deletion of coded study data already collected where retention remains necessary under the consent form, ethics approval, scientific integrity obligations, or applicable law.

9. Security

The University of Geneva and its study partners implement technical and organizational measures intended to protect personal data against unauthorized access, disclosure, alteration, or loss, including restricted access, secure transmission, and role-based handling of coded study data.

However, no online transmission or storage system can be guaranteed to be completely secure, and residual cybersecurity risks cannot be entirely eliminated.

10. Changes to this Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in the Portal, hosting arrangements, legal obligations, study procedures, or Google API requirements.

Any material changes will be published on this page together with an updated effective date.